Important Information
This Policy covers personal information processed for consultations, teaching, coursework and dissertation support, proofreading, AI-use compliance support, academic appeals, progression planning, open classes, recordings and payment services. Where we process identity documents, financial accounts, medical evidence, disciplinary or appeal records, or children's information, we will obtain any separate or explicit consent required by applicable law.
1. Scope and Our Identity
This Policy applies to websites, online forms, teaching platforms such as ClassIn, social-media accounts, customer-service channels, offline offices and payment functions operated by Yinggu (Hangzhou) Education Technology Co., Ltd. under the Phoenix EDU and Phoenix Education brands.
Depending on the service and applicable law, we act as the personal-information processor, controller or service provider responsible for the purposes and means described here. A third-party platform may separately control information processed under its own policy.
2. Information We Process
We may process:
- Identity and contact information, including name, age or year of birth, location, telephone number, email, WeChat ID and other communication accounts.
- Education information, including institution, programme, module, academic stage, timetable, grades, deadlines, tutor feedback and learning needs.
- Service materials, including assignments, research proposals, dissertations, data, code, presentations, appeal statements, evidence and revision records.
- Order and payment information, including service selection, amount, currency, transaction reference, invoice details, payment status and refund or dispute records. Full card credentials are generally handled by the payment provider rather than stored by us.
- Class and communication records, including attendance, messages, service-group records, lesson recordings, file versions, feedback and quality-control notes.
- Technical and security information, including IP address, device and browser information, timestamps, consent records, logs, cookies and fraud indicators.
- Sensitive information supplied for a justified purpose, such as identity documents, financial information, medical evidence, disciplinary records or information relating to a child.
Please avoid submitting information that is unrelated to the requested service.
3. Purposes and Legal Bases
We process information as necessary to take steps before entering a contract, perform a contract, comply with legal obligations, protect lawful interests, obtain consent or separate consent where required, and pursue legitimate interests where recognised by applicable law.
Purposes include responding to enquiries; assessing needs; creating and managing orders; matching tutors; scheduling and delivering services; reviewing materials; providing feedback; monitoring attendance and quality; processing payments and invoices; maintaining security; preventing fraud; handling complaints and disputes; complying with tax, accounting and legal duties; and improving services through appropriately aggregated or de-identified information.
Optional marketing, publication of identifiable testimonials, and materially different uses of sensitive information will rely on the relevant consent where required. Refusing optional marketing does not prevent purchase of the core service.
4. Sensitive Information and Separate Consent
Before processing identity documents, financial accounts, precise location, health information, disciplinary or appeal records, information about children under 14, or other information treated as sensitive under applicable law, we will explain why it is needed, how it will be used and any material effect, and obtain separate or explicit consent where required.
Access is limited according to role and case need. Users should redact irrelevant medical, financial, family and third-party details before uploading materials where possible.
5. Class Recordings, Case Studies and Publicity
Online classes may be recorded for review, quality assurance, safety or dispute handling. We will provide a classroom, product or other reasonable notice before recording. Users must not record or distribute a class without authorisation.
Identifiable student work, images, voice, recordings, testimonials or outcomes will not be used publicly without the permission required by law. Anonymised cases may be used to explain services where identifying details have been removed or generalised. Consent for future optional publicity can be withdrawn, although lawful use already completed cannot always be reversed.
6. Payments and Third-party Platforms
Payment providers may process wallet, bank-card, bank-transfer, anti-money-laundering and verification information under their own policies. We provide transaction information necessary to complete the payment and receive status, reference and dispute information.
ClassIn, WeChat, email, cloud storage, customer-management systems, video hosting, analytics and identity-verification providers may process information needed for service delivery. We select providers with regard to function, location, security and contractual safeguards, and seek to limit processing to agreed purposes.
The website's AI Content Detector processes English text and documents deliberately submitted by a user through the Phoenix-developed writing intelligence engine. Uploaded files and text are processed only as long as needed to complete upload, detection and report generation and are not written to an essay database. To preserve the original layout in a report, a Word file may be converted in a controlled temporary directory; that temporary copy is deleted immediately after conversion. Uploaded content and generated reports are removed from runtime memory when their short validity periods expire. We retain only a one-way access identifier, usage date, word count, aggregate risk score and number of higher-risk sentences for quota control, security and service statistics. Users should not submit identity numbers, contact details, medical records, school credentials or unauthorised third-party information.
Users should review the privacy terms presented by each third-party service. We are not responsible for a third party's independent processing outside our instructions.
7. Sharing, Processing on Our Behalf, Transfer and Disclosure
We do not sell personal information. Where necessary, information may be shared with or processed by matched tutors, academic operations staff, advisers, authorised group companies, IT and cloud providers, teaching platforms, payment providers, professional advisers and other vetted contractors.
Information may also be disclosed where the user directs us, where necessary to protect rights or safety, during a lawful business reorganisation with appropriate safeguards, or where required by a court, regulator or other lawful authority. Recipients receive only information reasonably necessary for their role.
8. International Processing and Transfers
We support students and engage tutors or service providers in several countries, including China, the United Kingdom, Australia, the United States, Canada, New Zealand and Singapore. Information may therefore be accessed, stored or processed outside the user's location.
Where cross-border transfer requirements apply, we will use an appropriate legal mechanism, such as separate consent, contractual safeguards, a statutory assessment or another permitted measure. We will consider the nature, amount, purpose, recipient, location, retention and security of the information.
9. Retention
We retain information only for service delivery, legal compliance, accounting, security and dispute handling. Typical periods include:
- Contracts, orders, payments, invoices and key consent records: at least three years after completion or transaction, and longer where accounting, tax or limitation rules require.
- Teaching, attendance, feedback and project records: normally during the service and for a reasonable quality and dispute period afterwards.
- Recordings and large working files: for the stated access or operational period unless a complaint, legal hold or contract requires longer retention.
- Enquiries that do not become customers: for a reasonable follow-up period, then deletion or de-identification.
- Security and access logs: for a period proportionate to security and fraud risk.
At the end of the applicable period, information is deleted, anonymised or securely archived with restricted access.
10. Information Security
We use measures proportionate to risk, which may include access controls, authentication, encrypted transmission, logs, confidentiality obligations, supplier review, backups and incident response. Internet and cross-border communications cannot be guaranteed completely secure, and users should protect passwords and school-system credentials.
If a security incident may materially affect users, we will investigate, contain and remedy it and provide notifications required by applicable law. Staff, tutors and suppliers are authorised only for the information needed for their roles.
11. Cookies and Similar Technologies
Necessary cookies may support login, security, language, order and payment functions. Non-essential analytics or advertising cookies will not be enabled without any consent required by law. Users can manage browser or cookie preferences, although disabling necessary cookies may affect website functions.
A detailed cookie list will be published if and when additional cookie-enabled functions are introduced.
12. Your Rights
Subject to applicable law, users may have rights to be informed, access or copy information, correct or complete it, request deletion, restrict or object to processing, withdraw consent, close an account, receive portable data, request explanation or human review of automated decisions, and complain to a regulator.
We may verify identity and authority before responding. Requests are handled within the period required by applicable law; straightforward requests are generally addressed within 15 working days, while requests subject to UK data-protection rules are generally addressed within one month, subject to lawful extensions.
Some information may be retained despite a deletion request where needed for contract, tax, fraud-prevention, legal claim or protection of another person's rights. Withdrawal of consent does not affect processing already lawfully completed or processing based on another lawful ground.
13. Children and Young People
A user under 18 should purchase and use paid services with a parent or guardian. Where information relates to a child under 14, we will obtain guardian consent and apply the protections required by Chinese law. Where UK rules concerning consent to direct online services apply, we will obtain or verify guardian authorisation for a child under 13.
A guardian who believes a child supplied information without authority may contact us. After verification, we will stop the relevant processing and delete or otherwise address the information as required.
14. Automated Decisions and Artificial Intelligence Tools
Rules and tools may assist tutor matching, risk detection, file classification, language analysis or AI-use compliance review. We do not rely solely on automated processing to make final decisions with significant effects on a student's academic status or appeal. Users may request human review where applicable.
We will not use identifiable dissertations, assignments, medical documents or appeal materials to train public-facing AI models without appropriate authorisation and safeguards. Before using an external AI tool, we assess necessity and may use de-identification, access restrictions or provider settings that limit model training.
15. Policy Updates
We may update this Policy to reflect changes in our services, technology, providers or law. Material changes will be notified through the website, a message, a notice or another appropriate channel. Where new consent is required, it will be obtained before the changed processing begins.
A change that materially expands the use, recipients or sensitivity of existing information will not be treated as retrospectively accepted merely through a silent update.
16. Contact and Complaints
Personal-information processor and service provider: Yinggu (Hangzhou) Education Technology Co., Ltd.
Brand: Phoenix EDU / Phoenix Education
Customer service: Phoenix Education's official online consultation channel
Postal address: Room 1201-1, No. 58 Pinghai Road, Shangcheng District, Hangzhou, Zhejiang 310051, China
When making a privacy request, please identify yourself, provide a verifiable contact method, identify the relevant order or account and describe the information and request. Users may also complain to a competent data-protection, consumer-protection or other regulatory authority, or seek a judicial remedy where available.